Overview
Title
Proposed Collection; Comment Request
Agencies
ELI5 AI
The Federal Housing Finance Agency (FHFA) wants to make sure companies that check the value of houses are doing a good job, and they are asking people to help by sharing their thoughts about the rules they have. They need permission to keep collecting this information for three more years, so they want to know if what they're doing is helpful or if there are better ways to do it.
Summary AI
The Federal Housing Finance Agency (FHFA) is inviting public comments on the "Minimum Requirements for Appraisal Management Companies" information collection as per the Paperwork Reduction Act of 1995. This information collection is intended for an extension review and approval by the Office of Management and Budget before its expiration in March 2025. The rules involve state-level requirements for registering and supervising appraisal management companies to ensure they comply with federal standards. FHFA is responsible for overseeing a portion of the reported data burden and is seeking feedback on its necessity, accuracy, and potential methods to reduce it.
Abstract
In accordance with the requirements of the Paperwork Reduction Act of 1995 (PRA), the Federal Housing Finance Agency (FHFA or the Agency) is seeking public comments concerning an information collection called the "Minimum Requirements for Appraisal Management Companies," which has been assigned control number 2590-0013 by the Office of Management and Budget (OMB). FHFA intends to submit the information collection to OMB for review and approval of a three-year extension of the control number, which is due to expire on March 31, 2025.
Keywords AI
Sources
AnalysisAI
The document presents a notice from the Federal Housing Finance Agency (FHFA) requesting public comments on the "Minimum Requirements for Appraisal Management Companies" as outlined in the agency's information collection initiative. This initiative, in line with the Paperwork Reduction Act of 1995, aims to collect input before an intended extension review by the Office of Management and Budget. At its core, the document outlines the federal rules and state-level requirements for registering and overseeing appraisal management companies (AMCs), crucial to maintaining compliance with national standards in real estate valuation practices.
Summary and Purpose
The commentary underlines the fundamental purpose of the FHFA's request for input, which revolves around aligning AMC operations with federal mandates. The agency seeks to gather feedback regarding the relevance and accuracy of the information collection and explore methods to streamline the reporting burdens placed on respondents.
Significant Issues
Complex Language and Legal Jargon: Throughout the document, there is a noticeable use of complex legal language and citations. This might be challenging for the general public or stakeholders unfamiliar with legal documentation processes, potentially hindering their understanding.
Procedure Clarity: The document briefly touches on confidentiality procedures for comment submission. These specifics could be expanded to prevent confusion among contributors.
Burden Estimate Description: The explanation of how the burden of reporting is distributed among federal agencies, including the reasoning for FHFA's minimal burden, is not adequately detailed. Clearer clarification might aid stakeholders in understanding the distribution better.
Potential Mail Delays: An alert about possible delays in physical mailing due to mail irradiation is present but could benefit from more emphasis to ensure it is not overlooked by those submitting comments by post.
Public Impact
At a broad level, this document impacts the public by influencing how appraisal management companies are regulated across states. The participation from relevant stakeholders is likely to shape these requirements to ensure they are practical, non-burdensome, and relevant.
Stakeholders' Implications
Appraisal Management Companies: These entities are the primary stakeholders and could experience both positive and negative effects based on the final rules established. Compliance might initially require adjustments in operational practices but eventually could lead to enhanced credibility and trust.
State Agencies: For state licensing and certifying bodies, this document emphasizes the creation and maintenance of a program to effectively oversee AMCs. While there may be increased administrative duties, there is a larger role to play in ensuring industry standards are maintained.
General Public and Homebuyers: Although indirectly affected, the ultimate goal is to protect consumers by ensuring that appraisals conducted adhere to consistent quality and practice standards, possibly leading to more accurate property valuations which benefit homeowners and potential buyers alike.
In conclusion, the document invites public engagement in shaping FHA regulations impacting appraisal management companies. However, navigating the document's legal intricacies and implications could pose challenges to some stakeholders. More accessible language and comprehensive explanations could enhance the effectiveness of the public feedback process.
Issues
• The document includes repetitive language and legal citations that may be overly complex for the general public to understand.
• The procedures for submitting confidential comments are referenced but not explicitly detailed in the document, potentially leading to confusion about the process.
• The burden estimate calculations and distribution method between agencies are described briefly without detailed explanation, which might make comprehension difficult for readers unfamiliar with such processes.
• Mentions of time-sensitive correspondence being potentially delayed by mail irradiation could be highlighted more prominently to better inform stakeholders about potential impacts on submission timing.
• The use of 60-Day notice terminology without a clear explanation of the procedural significance may be confusing to some readers.
• Technical jargon, such as references to specific sections of the Code of Federal Regulations (e.g., '12 CFR 1222.21(c)(1)(iii)') and United States Code (e.g., '15 U.S.C. 1639e(a)-(i)'), could be confusing without inline explanations.
• There is mention of FHFA's burden responsibility being only 10% for certain Information Collections, but lacks a deeper explanation of why FHFA, in particular, is assigned only this percentage.
• The address provided for mailing comments might be too detailed for casual stakeholders, who might feel overwhelmed by the additional information about mail delays and the specialized routing process.
• While the document discourages obscenities and threats in public comments, this might be perceived as non-essential information reducing document readability.